Product Recall & Incident Mangement
It is a mandatory requirement all entrants to the Food Production Unit understand and abide by all of FERA LTD Policies & Procedures.
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Document Reference Number | 3.4 |
Document Sub-Sections |
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Issue Number | 1.0 |
Issue Date: | 05/01/2024 |
Last Reviewed Date | 05/01/2024 |
Reviewed by | Board of Directors |
Next Review Date | Annualised 05/01/2025 (Earlier if any significant changes made or required). |
Responsible Officer(s) | Board of Directors |
Distribution |
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Storage | Stored on the intranet. |
Document Control | Uncontrolled Copy Unless Printed on Yellow Signed Paper or accessed on intranet. |
Amendments with date of amendment. | Nil |
Document Notes | Nil |
Intranet Link | |
Authorised by | Adeel Iqbal |
3.4.1a MANAGING INCIDENTS, PRODUCT WITHDRAWAL AND PRODUCT RECALL PROCEDURES
Incident Management Lead | Adeel Iqbal |
Policy Reviewed | 20 January 2024 |
Next Review | Annualised |
Our food safety system is built to reduce or eliminate the possibility of incidents occurring that affect food safety or legality. However we must be fully prepared in case of any incidents or any unexpected occurrences. This includes a traceability system as well as a robust product recall procedure.
3.4.1b PRODUCT INCIDENT AND RECALL STATEMENT, COMMITMENT TO FOOD SAFETY AND RESPONDING TO THREATS
Product Recall Procedure Statement | The purpose of this procedure is to provide an overview of FERA Ltd. product recall plan and to implement this in the event of a product recall.
A product recall is defined as ‘an action to remove food product from the market at any stage of the process, including that possessed by the consumer which may pose a threat to health, public health or food that does not fully meet required regulations’.
The procedure and this document takes into account advice in the public domain by the Food Standards Agency. |
Commitment to Food Safety | FERA has robust quality control procedures in place to ensure that our product is safe for consumption. In the event that any of our products pose any threat to consumer or public health FERA will protect the consumer and public health by ensuring an effective procedure is followed to identify and remove unsafe date product from the distribution chain. Retailers, consumers, and the relevant authorities will be informed in a fully transparent and quick way. |
Responding to Pandemics / Viral Threats | We take special precautions throughout all production runs to mitigate risk to staff members or the final consumer or anyone along the chain as a result of the covid-19 pandemic. We have consulted medical professionals to ensure our processes are absolutely safe.
We have also invested in Clean Air Technology to clear the environment of pathogens. If information comes to light regarding any new vectors or modes of transmission of this virus we will adapt our processes immediately. If any product has been affected in light of new information and is deemed to be in any way at all questionable then we will initiate recall procedures. |
3.4.1c PRODUCT RECALL PROCEDURE AND PROMPT ACTIVITY IN RESPONSE TO INCIDENTS
FERA must respond in a swift and immediate manner when any food product has a potential problem. All stages of date product production will be closely monitored and reported ‘live’ by the supervisor on site. A designated supervisor who will act as a food safety officer and quality control manager will always be on site during any product manufacture.
The first step in the recall procedure is the receiving of notice of an issue with product. Staff are trained in how to deal with this initial communication. This may be received from consumer reports, suppliers’ notifications, retailer notifications, local authorities, industry-wide issues, staff members and others.
Any potential product recall will be reported to the supervisor/board of directors who will call an immediate meeting of the board. At this point the investigation of the product recall will be carried out.
3.4.1d INCIDENT MANAGERS ROLE AND SCOPE OF LIASION
The Incident Manager’s role will include regular monitoring for any potential problems with the product and the industry as a whole. Manufactured product will only leave each stage of the production facility when authorised by The Quality Control Manager who be evaluating product on a ‘live’ and continuous basis.
This will include but not be limited to regular review with:
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3.4.1e POTENTIAL INCIDENTS THAT COULD OCCUR WITH PRODUCT
Examples of issues with our products which may result in incidents becoming ‘full recalls’:
· Ready‐to‐eat food product contaminated with pathogenic microbes (e.g. Salmonella)
· Food product physically or chemically contaminated (e.g. cleaning chemical, glass/metal/hard plastic fragments, mineral oil, allergens not stated on the packaging)
· Unsafe material found in products or damage to products (e.g. adulteration or tampering,
· temperature abuse) or notification of unsafe material in ingredients supplied to us
· Finished Product not correctly processed, to the extent that it may not be safe (e.g. undercooked, under‐cured)
· Inaccurate labelling (e.g. wrong weight/count/barcode/use by/storage instruction/allergen information)
Issue | Considerations |
Microbial contamination | Any pathogen, e.g. bacteria, viruses or parasites |
FSA warnings | |
Reports of any food safety incidents in which a product is implicated | |
Allergens | Any issue such as undeclared allergen, incorrect packaging or processing, quality control procedures not followed |
Labelling errors | Omission or error of labelling including use by dates |
Other contamination | This could potentially include foreign materials, chemical contaminants or toxins |
Packaging problem | Integrity of packaging, refrigeration issues during transport, faulty seals |
Tampering of product | |
A recall from a supplier | Obtain tracking information on each component |
Issue with specific ingredient | Obtain tracking information on each component |
Covid-19 pandemic | Any new information coming to light regarding vectors or modes of transmission Any staff being infected with the virus |
3.4.1f POSSIBLE CONSEQUENCES RELATING TO RECALLS
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3.4.1g ACTIONS TO BE TAKEN IN RESPONSE TO A FOOD SAFETY INCIDENT
The action taken will be dependent on the type of situation that has occurred. The following possibilities (not exhausted) will be taken into account:
Reason for recall | Action | Time frame |
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3.4.1h INFORMATION TO GATHER WHEN CONVEYING A FOOD SAFETY RELATED INCIDENT
INFORMATION TO PROVIDE TO AUTHORITIES IN THE EVENT OF A RECALL OR FOOD INCIDENT | |
Type of recalled product | This would include the type of date, country of origin |
Batch numbers | |
Distribution | Local, national, international |
Any reported health problems | Symptoms, illnesses, case reports |
Full label details of the product being recalled | |
Quantity of the product manufactured | |
Name and Contact Details for Lead Contact Person at FERA | Include direct dial contact details and include out of hours contact information |
3.4.1i IN THE EVENT OF A FOOD SAFETY INCIDENT THE FOLLOWING AGENCIES MUST BE NOTIFIED (non-exhaustive list)
Agency Name / Details | Contact Details |
Local Authority (London Borough of Waltham Forest Food Safety and Health Safety Department) | Waltham Forest Council Waltham Forest Town Hall Forest Road Walthamstow E17 4JF
Food safety and health and safety | London Borough of Waltham Forest |
SALSA | SALSA Bloxham Mill Barford Road Bloxham Banbury Oxfordshire OX15 4FF SALSA Helpline: 01295 477570 Email: info@salsafood.co.uk |
Micron 2 | Tel +44 (0) 1630 652095 Email@ info@micron2.com |
FERA Director | Adeel Iqbal (Adeel.iqbal@feralondon.com) 07470644135 |
FSA Food Incidents Helpline | 02072768448 |
Packaging Issues | Stribbons UK, Ltd. UK Offices The Linden Building Regent Park, Off Booth Drive Wellingborough, Northants, NN8 6GR United Kingdom
Contact Name: Collette Chasseaud Mobile: 07885912002 Tel: +44 (0) 1933 675012 |
3.4.2a TRACABILITY INVOLVED IN FOOD SAFETY INCIDENTS INCLUDING FULL FORWARD AND FULL REVERSE TRACING.
FORWARD TRACE TESTING | |
1 | Start from a hypothetical warning from a supplier or source regarding a randomly selected raw material |
2 | Ascertain key information regarding product name, expiry and batch number |
3 | Search goods in records to see if product entered site |
4 | If affected material / product did not enter site, end of exercise |
5 | If affected material / product did enter site, search production records |
6 | Check to see how many items the product was used in and record |
7 | View batch numbers generated of those products in which the affected material was used |
8 | Check dispatch records – if batch numbers do not appear in the dispatch notes, this suggests affected materials has not been sent to the public domain and remains on site. |
9 | Search for all affected materials, quarantine and discard & assess for cross-contamination risk |
10 | If affected material appear on dispatch records, search all clients / customers / consumers that received the affected products and issue recalls. |
REVERSE TRACE TESTING | |
1 | Start from a hypothetical complaint regarding a random product from a client or consumer |
2 | Indicate a hypothetical fault with a component of the product |
3 | Trace that component back to source |
4 | Ascertain key information regarding product name, expiry and batch number |
5 | Access the dispatch records and use the batch number of the affected product to determine key information |
6 | Determine the batch number of the affected ingredient |
7 | Search production records to see where this batch of ingredient was used |
8 | Search the goods in sheet to see when, where and from which supplier the batch was obtained |
9 | Take corrective actions / inform supplier of issue |
3.4.2b ALGORITHM FOR INITIAL MANAGEMENT OF POTENTIAL PRODUCT RECALL
Always review internal and external (FSA) guidance on incident management
Potential for recall identified by any staff member / public /authority or other source |
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Duty Manager Notified |
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Food safety officer to document issue on complaints form and evaluate the urgency of the category of recall |
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Review Internal and external (FSA) incident guidance and procedures Incident Management Plan: Chief Executive Officer foreword | Food Standards Agency |
a) If Immediate recall required -emergency sitution declared and Safety Committee and Directors immediately notified b) If immediate recall not required, convene a sitting of the Safety Committee |
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Safety Committee to categorise the recall situation as 'immediate recall required' or non-immedate recall required'. |
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Immediate product recall if there are health and safety risks such as: product contamination with harmful agents, undeclared allergens, labelling errors, packaging defect causing damage to safety of product, product adulteration, substitution or food crime. |
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If Immediate recall required -emergency sitution declared and Safety Committee and Directors immediately notified b) If immediate recall not required, convene a sitting of the Safety Committee. Isolate the suspected product and hold all packaging and delivery |
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Isolate the suspected product and hold all packaging and delivery |
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Action taken |
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Action continuously reviewed and minimum of 2 hourly sittings of the Safety Committee if recall procedure initiated |
3.4.2c STANDARD OPERATING PROCEDURE OF THE FOOD SAFETY COMMITTEE
1. The committee shall convene as per the outlined algorithm
2. If a product recall is not required the proceedings will be documented and this will be recorded in the Incident Report log. Incident reports will be evaluated according to the incident reporting policy which will involve regular review by senior management
3. If product recall is required, the committee will work with the categorisation table as above to determine the urgency of the situation. At this point the safety committee will form the ‘Recall Committee’
4. A record keeper will be present at all times with the Chairman of Recall Committee to document all proceedings and actions as they occur
5. The chairman will co-ordinate all activities and required actions
6. Action will be taken according.
7. When any category of recall is required the company directors will be informed
8. When any category of recall is required all retailers will be informed
9. Further staff may need to be engaged as appropriate with required expertise – e.g. legal, purchasing, nutrition ETC.
3.4.2d CHECKLIST OF INITIAL ACTIONS TO BE CONDUCTED BY THE FOOD SAFETY COMMITEE
Checklist to Complete for Incident Management / Product Recall | Completed |
Determine the potential problem with product and confirm with the highest degree of accuracy | |
Determine schedule/time-frame for recall procedure | |
Appoint a record keeper to document all proceedings as they occur with time and date stamps | |
Notify and keep in regular contact with any external agencies such as Food Standards Agency, London Borough of Waltham Forest Council | |
Determine the product identification code and date and site of manufacture Batch numbers, up to date ingredients lists, packaging records and delivery records will need to be obtained Consider whether product has been rebranded or repackaged | |
Determine the level of recall – complete, partial | |
Ascertain where all parts of the problem stock is located and document this carefully This could include shipping/cargo from farms, in transit from ports to warehouse facility, incoming or outgoing delivery vehicles, cold storage areas in the production facility, in the main production area of the site, packaging area, ‘finished product’ area of cold storage, delivery out areas, in transit to retailers, stock with retailers, stock sold by retailers and in possession of consumer | |
Hold all current deliveries to ensure safety of product | |
Notify all locations of where product has been sent onwards and the methods by which this occurred | |
Identify, on conjunction with retailers, potential consumers of the suspected product | |
Appoint a contact point for external organisations and create a distribution list to disseminate information | |
Consider sample analysis requirements | |
Consider implementing a telephone hotline if the customer services line may not be adequate | |
Isolate suspected product and label it as unsafe as soon as possible | |
Remove suspected product from packaging and delivery areas | |
Cascade relevant information to on site staff | |
Put up a Food Recall Notice & Communicate the recall using methods as described including placing a notification online |
3.4.2e VERIFYING THE EFFECTIVENESS OF THE RECALL PROCEDURE
FERA’s Recall Committee shall determine how effectively the recall is progressing. When a recall procedure has been activated the committee shall meet at a minimum of 2 hourly until the recall has been stood down.
A traceability record will be maintained. The committee shall verify that all distribution of recalled dates has been stopped, that retailers have stopped selling the recalled stock.
Note: all date products have a batch number which will help to identify the origin of the date and what processes have occurred to it up to its final production.
3.4.2f MANAGEMENT OF RECALLED PRODUCT(S)
The Recall Committee will determine the most appropriate method of recovering recalled product. They will liaise with the distribution team about the use of vehicles. A ‘recovery site’ will be set up which will be a different site to the main production facility to ensure separation from any other dates or date products and to prevent the re-entry of recalled dates onto the market.
The batch codes of the recovered products must be accurately recorded and cross checked against our database. All above documentation will then be stored in a ‘Recalled Products’ file.
The committee will then liaise with the Quality Control Manager to determine what to do with the recalled dates. An assessment process with then occur. Recalled dates may require correction if this is appropriate or destruction in line with required process. The local authority will be informed of the outcome and be communicated with throughout the whole process. The local authority may be invited to witness the correction or destruction process as appropriate. The action taken will be recorded in the ‘Recalled Products’ file.
3.4.2g PREVENTION OF FUTURE SIMILAR RECALLS
Following the full course of action required for the recall, a forum will be set up with a learning environment to ensure that a similar or related issue does not occur again. This may require revision of existing procedures or new procedures being put in place.
3.4.2h FOOD SAFETY INCIDENT MANAGEMENT FORM
Food Safety Incidents are dealt with in a systematic and uniform way using our internal form which allows all aspects of the policy and procedure to be covered.
FOOD SAFETY INCIDENT MANAGEMENT FORM |
3.4.2i INCIDENT MANAGEMENT AND PRODUCT RECALL PROCEDURE REVIEWS
The product recall procedure will be periodically tested to ensure that it is fit for purpose and is effective and efficient in removing any unsafe products from the chain of distribution. Reference will be made to this procedure in all review meetings of the Safety Committee.
3.4.3a MOCK PRODUCT RECALL LOG
DATE | CONDUCTED BY (Name & Designation) | REASON FOR TRACE EXERCISE | PRODUCT RECALL EXERCISERESULT | EVIDENCE | NOTES / ACTIONS / DEADLINES / RESPONSIBLE OFFICER |
23 January 2024 | Adeel Iqbal (Director) | Mock Test Exercise | PASS | Repeat within 1 year | |
3.4.3b FORMAL 'REAL-WORLD' PRODUCT RECALL(S)
DATE | CONDUCTED BY (Name & Designation) | REASON FOR TRACE EXERCISE | PRODUCT RECALL EXERCISERESULT | EVIDENCE | NOTES / ACTIONS / DEADLINES / RESPONSIBLE OFFICER |